Putting the SEC’s CanAccord No Action Letter into the EB-5 Context

On January 18, 2002 the SEC issued a ‘No Action’ letter to CanAccord Capital Corporation (“CanAccord”), which was actively seeking “investments” for an immigrant investor program in Quebec, Canada. Unlike section 203(b)(5) of the Immigration and Nationality Act, the statute governing the Quebec immigrant investor program explicitly provides for reimbursement. Act Respecting Immigration to Quebec… Read More

The U.S. Asia-Pacific Economic Cooperation Business Travel Card Program

After brief correspondence with a colleague who travels to China frequently, it became apparent that the U.S. Asia-Pacific Economic Cooperation Business Travel Card (“ABT Card”) Program is not as well-known as it ought to be. Since DHS will stop issuing these cards on September 18, 2018 people who travel to China regularly for business, such… Read More

What can CBP see? Brief Notes and Comments on DHS Border Crossing Information (BCI) System of Records – 81 FR 89957

On December 13, 2016 the Department of Homeland Security (“DHS”) published notice in the Federal Register regarding updates to its Border Crossing Information (“BCI”) System of Records, as required by the Privacy Act of 1974 (5 USC 552a). Comments may be submitted until January 12, 2017. Brief note on what Customs and Border Protection can… Read More